How’s Your Hazmat Training?

The federal hazardous materials transportation regulations require the training of all hazmat employees. The purpose of training is to increase employees’ safety awareness and to reduce hazmat incidents.

Any employee who meets the U.S. Department of Transportation’s (DOT) definition of a “hazmat employee” must be trained, tested, and certified by the employer to be able to successfully perform his or her hazmat duties.

The regulations define hazmat employee as a person who is employed by a hazardous materials employer and "directly affects hazardous materials transportation safety." Specifically, this includes employees who:

• Load, unload, or otherwise handle hazmats
• Operate vehicles transporting hazmats
• Test, repair, modify, mark, or otherwise represent packaging as qualified for transporting hazmats
• Are responsible for safety in the transportation of hazmats

But the intention of the training regulation is broad. The rules clearly intend that anyone who has any impact on the safety of hazmats in transportation is considered a hazmat employee. For example, an office assistant who types the required hazardous materials description on a shipping paper at the direction of another is a hazmat employee and must be trained, tested, and certified.

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Key Training Issues

• All hazmat employees should have "awareness" training that addresses security risks associated with hazmat transportation and methods designed to enhance transportation security. In-depth security training is required for workers of employers who are required to have a security plan.

• A new employee or an employee who changes position may perform hazmat functions provided he or she is under the direct supervision of a properly trained and knowledgeable hazmat employee, and the hazmat training for the new or transferred employee is completed within 90 days of employment or change in job function.

• Relevant training received from a previous employer or another previous source may be used to satisfy the requirement provided a current record of the training is available.

• A training record must include the hazmat employee’s name, completion date of the most recent training, training materials, name and address of hazmat trainer, and certification that the hazmat employee has been trained and tested.

• Refresher training is required at least once every 3 years. Security awareness training at an employee’s next scheduled retraining or within the 3-year cycle. If the security plan for which training is required is revised during the 3-year recurrent training cycle, refresher training must be provided within 90 days of implementation of the revised plan.

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• A record of current training including the preceding 3 years must be created and retained for as long as the employee is employed by that employer and for 90 days thereafter.

• Specific training requirements for air, vessel, and highway hazmat transportation have been developed by DOT agencies that regulate those modes of transportation.

What’s “Adequate Training”?

DOT has written a letter of interpretation that states the agency’s position on the meaning of “adequate training” for hazmat employees.

The letter says that responsible hazmat employers, either individually or through industry associations, are best qualified to determine the training needs of their employees. “No attempt has been made to specify the level and duration of training or testing,” states the letter.

Employers are, however, required to present training information clearly and accurately and in a manner that can be understood by employees of varying literacy and language skills.

In tomorrow’s Advisor, we’ll look at hazmat training guidance from PHMSA, and introduce a training resource library for transportation safety issues.